Whistleblowing Policy

What does this policy cover, and who is covered?

All employees, contractors, consultants, officers, interns, casual and agency workers are covered by this policy.

It sets out what they should do if they have reason to believe that something dangerous, unlawful or unethical is going on at work and it is affecting (or risks affecting) them or other colleagues.

When you report these kinds of concerns, this is called whistleblowing.

We are committed to operating at all times, and in everything that we do, to the highest standards of integrity.

However, all organisations can occasionally be affected by conduct that is dangerous, against the law or breaches ethical or professional codes.

Please follow the procedure outlined at Part II of this policy to immediately report any concerns that you have about this kind of conduct, so that we can take the necessary action to address these concerns as fast as possible.

This policy also covers the actions of third parties such as suppliers, service providers, and clients, as well as our staff. If you are concerned about a third party, please also raise them with us before approaching anyone else. Paul Mersh (Managing Director) will be able to explain how you should proceed.

We will always take your concerns seriously and they will be thoroughly investigated by appropriate personnel. Most importantly, you should feel confident to follow the Part II procedure with confidence. There will be no reprisals for individuals who bring these concerns to our attention – we value and respect all such reports and those who make them to us. We all play an important role in ensuring that our business and everyone working in and with it acts professionally, lawfully and appropriately.

1. It is not part of your employment contract

This policy is not part of your employment contract. cer Financial may amend this policy at any time.

1. What sorts of activities are typically considered relevant to whistleblowing?

This is not an exhaustive list, but the types of concerns you may want to raise with us by whistleblowing could include:

• Any activity you suspect is criminal.
• Any activity you suspect puts health and safety at risk.
• Any activity you suspect may damage the environment.
• Any activity you suspect breaches our policy on bribery and corruption.
• Any failure to comply with legal or regulatory obligations.
• Any failure to meet professional requirements.
• Any attempt to conceal one or more of these activities.

Please speak to Paul Mersh (Managing Director) if you are unsure whether something that you are concerned about is covered by this policy.

Bullying or harassment

If your complaint is about the behaviour of others towards you, our Bullying and Harassment Policy or Grievance Policy contain the relevant guidance on how to proceed. These types of behaviour are not covered by this Whistleblowing Policy.

1. Confidentiality and anonymity

You are always encouraged to raise concerns openly, and we actively discourage anonymous whistleblowing. This is because it is not always easy to manage and investigate anonymous reports. If we are unable to ask you for clarification or further details, we may struggle to gather sufficient evidence or reach an informed conclusion.

However, if you prefer to keep your identity anonymous, we will do all that we can to preserve your anonymity and the confidentiality of your concerns, where possible. If we need to disclose your identity as part of the investigation, we will discuss this with you beforehand and explain the reasons.

We will protect you from reprisals, and you can read more about how we do this in Section 5 below.

1. We protect whistleblowers

This policy is intended to comply with the Public Interest Disclosure Act 1998 and the whistleblowing provisions of the Employment Rights Act 1996.

There are no reprisals for mistakes or where, following a thorough investigation, we conclude that there has been no breach of law, policy or unethical conduct. However, to qualify for protection, the disclosure must, in the reasonable belief of the worker making the disclosure, show that one or more of the following has happened, is happening or is likely to happen, and that it is in the public interest to make the disclosure:

• A criminal offence.
• Failure to comply with any legal obligation.
• A miscarriage of justice.
• Danger to the health or safety of any individual.
• Damage to the environment.
• Deliberate concealment of any of the above.

If at any time you do not feel that you have been fairly or properly treated in the handling of your whistleblowing concern, you must inform us immediately. You should inform Paul Mersh (Managing Director) in the first instance; if you are not satisfied with the outcome, you should follow the process set out in our Grievance Policy.

We also protect whistleblowers from reprisals by others. Where a whistleblower reports inappropriate treatment, including threats as a result of raising concerns, we will investigate and may take disciplinary action, which could include dismissal for gross misconduct.

If you would like more information about your rights as a whistleblower and how you are protected, you can contact Protect, the UK's independent whistleblowing charity.

1. Whistleblowing to others outside of cer Financial

Our policy covers the process for raising, investigating and resolving wrongdoing within cer Financial's workplace.

The whistleblowing procedure has been designed to ensure that, wherever possible, concerns are resolved internally while protecting those who raise them.

We recognise that, in exceptional circumstances, you may wish to involve an external body, such as an appropriate regulator, or seek confidential advice from Protect, the UK's independent whistleblowing charity.

Involving the press/media

Involving the media in a whistleblowing matter often has the effect of inflaming the situation rather than assisting it. It can significantly hamper evidence gathering and the willingness of relevant individuals to support the process.

We therefore strongly discourage involving the media. We would generally expect you to have taken all reasonable steps to deal with the matter internally or with an appropriate external regulator before considering any wider disclosure.

Part II – Our Procedure for Raising a Whistleblowing Concern

Please follow this procedure:

1. Raise your concerns with Paul Mersh (Managing Director) in the first instance, either in writing or in person.
2. If you would prefer not to discuss your concerns with Paul Mersh, or you consider the matter to be particularly serious, write to Alexandria Broadway (Office Manager).
3. Explain that you are raising your concerns under the cer Financial Whistleblowing Policy and provide all relevant facts, including names and dates where possible.
4. You will be invited to a meeting to discuss your concerns. You may be accompanied by a work colleague or, where applicable, a trade union representative. Anyone attending must maintain strict confidentiality.
5. We will investigate the concerns thoroughly and may involve appropriate internal or external specialists where necessary.
6. We will keep you informed of progress wherever possible, although there may be legal or confidentiality reasons why certain information cannot be disclosed.
7. If you are dissatisfied with the outcome, you may ask Alexandria Broadway (Office Manager) to review the investigation.
8. Anyone raising a concern in good faith will be supported and protected. However, knowingly making a false or malicious allegation may result in disciplinary action.